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is not liable for any tax, interest, or additions to tax
resulting from any deductions, losses, investment credits,
business energy investment credits, or any other tax benefits
claimed by Allan J. Becker on his 1981 and 1982 tax returns as a
result of his participation in the Plastics Recycling Program.
Allan J. Becker did not tell Brenda Becker that he was investing
in the Partnership transactions, nor did he inform her that he
was filing an application for refund for taxable year 1979.
Hereinafter, references to "petitioner" shall be to Allan J.
Becker.
After graduating high school, petitioner worked for 3 years
as a draftsman with a division of Sherry Rand, and also attended
college classes at night. In 1960 petitioner joined his father's
food brokerage company, Sidney Becker Associates, Inc. (SBA).
Petitioner handled sales in the New York metropolitan area. By
1981 petitioner had acquired 49 percent of SBA and was an officer
of the company. SBA's gross sales during the years 1981 and 1982
ranged from $400,000 to $500,000.
Petitioner acquired a 0.671946-percent interest in SAB
Recovery for $7,500 in 1981. As a result of his interest in SAB
Recovery, on his 1981 return petitioner claimed an operating loss
in the amount of $5,955 and investment tax and business energy
credits in the amount of $12,380. He claimed a loss in the
amount of $344 from SAB Recovery on his 1982 return. Petitioner
acquired a 0.507692-percent interest in SAB Recycling for $5,000
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